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often heard Mr. Simonds say that the line of the grant of the Company's lands (by which he understood Hazen, Simonds and White) ran from Red Head to the Keonebecasis. Some time before 1774 he was at Red Head with Mr. Simonds who on being asked if his bounds extended so far answered that they did, that they extended to a small brook on the further side of the head. Knows the part of the grant now in controversy and has mowed hay there as long ago as 1768 and 1769 for the Company. He was originally employed and sent down by Mr. Hazen and was frequently told by Mr. Simonds that he must consider himself as much in Mr. Hazen's employ as in his. Mr. White was always concerned in getting the hay. In June last, being at work upon the fence upon the marsh, James Simonds told him that when he found his grant was bounded at Red Head and that the course took in so much water, he went to Mr. Morris the surveyor general and asked where his bounds were, who told him it began at a large red head on the east side of the Bay as you go into the harbor, and after some conversation admitted he did not know it took in so much water and asked Mr. Simonds if there was no other Red Head; Simonds told him there was one at Little River. Morris told him he might go and mark his bounds there. Accordingly Simonds came home and marked his bounds there. Morris said it was opposite Partridge Island.

Moses Greenough came to St John to live in 1773; was here also in the years 1738 and 1759 when the large high bluff head between the south point of the City and Point Mispec was called Red Head. Went with Lemuel Cleveland to look at the Red Head Marsh, but was informed by Cleveland it belonged to Mr. Simonds and so gave up all further thought of getting lands there. In driving cattle, at which he used to be frequently employed, they used to speak of going from Red Head to Little River. Never heard of little Red Head.

Lemuel Cleveland came to St. John to live in 1774, but was in the country when the French had a fort, where Mr. Simonds house now stands, about the year 1757. He remembers the direction of the Pilot, when he came into the harbour at that time from Windsor, to steer by Red Head so as to avoid the flats. He was told by Simonds the land at Red Head and on this side belonged to him and the Company.

Robert Coltart says he knows the lot of land granted to Richard Walker bounded upon Red Head. In the month of January, 1785, he married the widow of the said Richard, and in the autumn of 1787 James Simonds and two of his sons came down to Red Head, and in the course of conversation said that he was glad to see the head produced so good grain, that he never thought it could, that he was glad of it because he was a neighbor, that he owned the land adjoining thereto.

William Oliver says that while he was at work upon the dyke near the new aboideau he heard Mr. Simonds complain of Hazen's having sold a lot of land at Red Head to Joseph Russell, there being then a dispute about the title of the land in the Chancery Court. He saw James Simonds, Jun'r., when the last